POLICY FOR PRESERVATION OF DOCUMENTS

SRS LIMITED (Adopted on 01.12.2015)

POLICY FOR PRESERVATION OF DOCUMENTS In compliance with Regulation 9 of the Securities Exchange Board of India (Listing Obligations

and Disclosure Requirements) Regulations, 2015 ("Regulations")

1. Preface The Board of Directors (the "Board") of SRS Limited (the Company) has approved the following Policy (the "Policy") for preservation of Documents/ Records maintained by the Company either in Physical Mode or Electronic Mode (hereinafter referred to as the Documents) on 1 s t December, 2015.

This Policy has been formulated in accordance with Regulation 9 of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015.

2. Scope A policy on preservation of Documents would ensure safekeeping of the records and safeguard the Documents from getting manhandled, while at the same time avoiding superfluous inventory of Documents. The Policy is also made to aid the employees in handling the Documents efficiently. It not only covers the various aspects on preservation of the Documents, but also the safe disposal/destruction of the Documents.

3. Definitions -

3.1 "Act" means the Companies Act, 2013.

3.2 "Applicable Law" means any law, rules, circulars, guidelines or regulations issued by Securities Exchange Board of India (SEBI), Ministry of Corporate Affairs (MCA) and The Institute of Company Secretaries of India (ICSI) under which the preservation of the Documents has been prescribed.

3.3 "Authorized Person" means any person duly authorized by the Board.

3.4 "Board''' means the Board of directors of the Company or its Committee.

3.5 "Company" means SRS LIMITED.

3.6 "Current Document(s)" means any Document, which still has an ongoing relevance with reference to any ongoing litigation, proceedings, complaint, dispute, contract or any like matter.

3.7 "Document(s)" refers to papers, notes, agreements, notices, advertisements, requisitions, orders, declarations, forms, correspondence, minutes, indices, registers and or any other record, required under or in order to comply with the requirements of any Applicable Law, whether issued, sent, received or kept in pursuance of the Act or under any other law for the time being in force or otherwise, maintained on paper or in Electronic Form and does not include multiple or identical copies.

For the purpose of this policy, document may include the following: i . 'books and papers' as defined in clause 12 of section 2 of the Companies Act, 2013; i i . 'books of accounts' as defined in clause 13 of section 2 of the Companies Act, 2013; i i i . 'documents' as defined in clause 36 of section 2 of the Companies Act, 2013; iv. 'registers' as defined in clause 74 of section 2 of the Companies Act, 2013

3.8

3.9

3.10

3.11

3.12

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6.1

6.2

6.3

6.4

"Electronic Record(s)" means the electronic record as defined under clause (t) of subsection (1) of section 2 of the Information Technology Act, 2000.

"Electronic Form" means any contemporaneous electronic device such as servers, computer, laptop, compact disc, floppy disc, pen drive, space on electronic cloud, or any other form of storage and retrieval device, considered feasible, whether the same is in possession or control of the Company or otherwise the Company has control over access to it.

"Maintenance" means keeping Documents, either physically or in Electronic Form.

"Preservation" means to keep in good order and to prevent from being altered, damaged or destroyed.

"Regulations" means the Securities Exchange Board of India (Listing Obligation and Disclosure Requirements) Regulations, 2015. The words and phrases used in this Policy and not defined here shall derive their meaning from the Applicable Law.

Administration The compliance officer of the Company (the "Administrator") shall be in-charge of administration of this policy and the implementation process and procedures to ensure that Documents Preservation Schedule is followed.

Classification The preservation of Documents shall be done in the following manner:

a) Where there is a period for which a Document is required to be preserved as per Applicable Law, for the period required by Applicable Law.

b) Where there is no such requirement as per Applicable Law, then for such period as the document pertains to a matter which is "Current".

c) In case of any other Document, for such period, as a competent officer of the Company required handling or deal with the Document takes a considered view about its relevance; Provided that generally speaking, a Document may be preserved for a period of 5 years from the date on which the Document was originated.

Documents preservation Schedule is given in Annexure -1

Modes of preservation

The Documents may be preserved in o Physical form or o Electronic Form.

The officer of the Company required to preserve the Document shall be Authorized Person who is generally expected to observe the compliance of requirements of Applicable Law

The preservation of Documents should be such as to ensure that there is no tampering, alteration, destruction or anything which endangers the content, authenticity, utility or accessibility of the Documents.

The preserved Documents must be accessible at all reasonable times. Access may be controlled by Authorized Person with preservation, so as to ensure integrity of the Documents and prohibit unauthorized access. ..

7. Custody of the Documents Subject to the Applicable Law, the custody of the Documents shall be with the Authorized Person. Where the Authorised Person tenders resignation or is transferred from one location of the Company to another, such Person shall hand over all the relevant Documents, lock and key, access control or password, or Company Disc, other storage devices or such other Documents and devices in his possession under the Policy. The Board may authorize such other person as it may deem fit as the Authorised Person.

8. Authority to make alterations to the Policy The Board is authorized to make such alterations to this Policy as considered appropriate, subject, however, to the condition that such alterations shall be in consonance with the provisions of the Acts and Regulations.

9. Destruction of Documents

9.1 Destruction as a normal administrative practice usually occurs because the records are duplicated, unimportant or for short term use only. This applies to both Physical and Electronic Documents.

9.2 The temporary Documents, excluding the Current Document(s) shall be destroyed after the relevant or prescribed period, by the Authorised Person in whose custody the Documents are stored, after the prior approval of the Board or any other authority as required under the Applicable Law pursuant to which the Documents have been preserved. The categories of Documents may be destroyed as normal administrative practice are listed in Annexure I I

9.3 A register of the Documents disposed/destroyed shall also be maintained in accordance with Annexure-III. It shall state the brief particulars of the Documents destroyed, date of disposal/destruction and the mode of destruction.

9.4 The entries in the register shall be authenticated by the Authorised Person.

10. Conversion of the form in which the Documents are preserved

10.1 The physical Documents preserved may be converted, whenever required or felt necessary, into electronic form to ensure ease in maintenance of records and efficient utilization of space.

10.2 This wil l be done after obtaining prior approval of the Board.

11. Authenticity Where a Document is being maintained both in physical form and in Electronic form, the authenticity with reference to the physical form should be considered for every purpose.

12. Communication Copy of this policy duly approved by the Board of Directors shall be forwarded to Human Resource Development (HRD) Department and HRD Department is required to notify & communicate the existence and contents of this policy to the employees/ functional head including CFO/ COO of the Company. The new employees shall be informed about the policy by the Human Resource Development department.

13. Interpretation In any circumstance where the terms of this policy differ from any existing or newly enacted law, rule, Regulation or standard governing the Company, the law, rule, Regulation or standard

will take precedence over these policies and procedures until such time as this policy is changed to conform to the law, rule, Regulation or standard.

Annexure - 1

DOCUMENTS P R E S E R V A T I O N S C H E D U L E

The Records of the Company may be classified as follows: -

• Corporate Records • Accounts and Finance Records • Tax Records • Legal Files and Records • Property Records • Projects Records • Correspondence and Internal Memo • Insurance Records • Personnel Records

Corporate Records Sr. No.

Record Type Preservation Period

1. The Memorandum and Articles of Association of the Company Permanent 2. Affidavit/Consent from the Subscribers to the Memorandum and from

persons named as the First Directors Permanent

3. All Statutory Registers 4. Books and Documents relating to the issue of share certificates,

including the blank forms of share certificates Permanent

5. Minutes book of Board, Committee's and General Meeting Permanent 6. Licenses & Permissions Permanent 7. Common Seal Permanent 8. Statutory Forms excluding routine forms Permanent 9. Annual return 8 years from the

filing with MCA 10. Attendance Registers-Board, Committee and General Meetings 8 financial years 11. Office Copy of Notices of General Meetings, Scrutinizer's Report and

Related Papers 8 financial years or

as long as they remain current

12. Office Copy of Notice, Agenda, Notes on Agenda, Scrutinizer's Report and Related Papers of Board/Committee Meetings

8 financial years or as long as they remain current

13. Al l notices pertaining to disclosure of interest of directors 8 years 14. Al l certificates surrendered to a company 3 years from date of

surrender

Accounts & Finance Records Sr. No.

Record Type Preservation Period

1. Annual Audited & Financial Statements Permanent 2. Books of Accounts, Ledgers & Vouchers 8 years 3. Bank Statements 8 years 4. Investment Records 8 years

5. Annual Plans & Budgets 5 years 6. General Correspondence 2 years

Tax Records Sr. No.

Record Type Preservation Period

1. Excise Returns, Income Tax Returns, Sales Tax Returns, Service Tax Return or any Return filed under any other tax applicable to the Company

Permanent

2. Tax Exemptions and Related documents 8 years 3. Documents, Challans and other details/correspondence related to

Excise, Income Tax, Sales Tax, Service Tax or any other tax applicable to the Company

8 years from the end of Financial Year or after completion of assessment under applicable law,

whichever is later

Legal Files and Records Sr. No.

Record Type Preservation Period

1. Court Orders Permanent 2. Contracts, Agreements and Related correspondence (including any

proposal that resulted in contract and other supportive documentation) Permanent

3. Legal Memoranda and Opinions including subject matter files 3 years after close of the matter

4. Litigation Files 3 years after close of the Litigations

Property Records Sr. No.

Record Type Preservation Period

1. Original Purchase and Sale Agreements/Deeds Permanent 2 Property Card, Ownership Records issued by any Government

Authority Permanent

Projects Records Sr. No.

Record Type Preservation Period

1. Project sanctions and approval Permanent 2. Other Documents and Related correspondence 8 years from the date

of completion of the project

Correspondence and Internal Memo Sr. No.

Record Type Preservation Period

1. Those pertaining to non-routine matters or having significant lasting consequences

8 years

2. Correspondence and Memo pertaining to routine matters and having no significant impact lasting consequences

2 years

Insurance Records Sr. Record Type Preservation Period

No. 1. Master Policies and related documents Permanent 2. Policies for movable/immovable assets, vehicles etc. 2 years from the date

of expiry. However, in case of any claims pending in respect of

such policies, the same shall be

preserved ti l l the settlement of such

claims. 3. Inspection/Survey Reports 2 years 4. Claim Records 12 months after

settlement of the claims

Personnel Records Sr. No.

Record Type Preservation Period

1. Master Policies of the Company Permanent 2. Payroll Registers 8 years 3. Bonus, Gratuity and other statutory records 8 years 4. Unclaimed Wages Records 8 years 5. Employee Information Records 2 years after

separation

Annexure - I I

The following categories of Documents may be destroyed as normal administrative practice: S Catalogues; •f Copies of press cuttings, press statements or publicity material; S Letters of appreciation or sympathy, or anonymous letters; S Requests for copies of maps, plans, charts, advertising material etc.; S Telephone message; J Drafts of reports, correspondence, speeches, notes, spread sheets, etc.: and •S Routine statistical and progress reports compiled and duplicated in other reports.

Annexure - I I I The format of the register of Documents disposed/destroyed -

Sr. No. Particulars of Documents Destroyed Date and Mode of Destruction with the initials of Company Secretary or other authorized Person